I just read a number of proposals that deal with catch and release. A couple would require barbless hooks when going to catch and release. So here is the Department's comment:
However, we do not support a regulation requiring the
practice because of the negative effects it would cause to sport fishing opportunity in the absence
of a measurable biological benefit. The department is NEUTRAL on allocative aspects of this
If you read the text of the comment they note that some states require this and others do not for various reasons. In States where it is required there are social and biological considerations.
What gets me about the above comment is that it makes a determination that a metric for effect cannot be measured so reducing sport fishing opportunity is not acceptable to the Department. But then it says the department is neutral on the allocation aspects of this proposal. Is not reducing sport fishing opportunity regardless of a biological metric allocation?
One can also question the Department comment on absence of a measurable impact of barbless hooks. How would one know that without a specific example where it is being applied and an evaluation of what constitutes a measurable metric. Also the absence of something does not mean it does not take place. States that have barbless hook regulations obviously think it has a measurable impact - the Department cites endangered species management as an example of an application.
This is the type of comment that drives the public crazy. Obviously the Department does not want a barbless hook regulation because of opportunity concerns.
To me the Department should in this case just state the facts on catch and release and barbless hooks and then take a neutral position.
Comments on prohibiting catch and release fishing are in the same vein. The Department is opposed but is not catch and release fishing also a social issue? One does not need catch and release fishing when a fishery is nearly closed for conservation reasons. While I see the value of catch and release in certain situations I think the Department read the intent of the proposed regulations very narrowly. The proposals are not well thought out because there are situations that catch and release must happen - king salmon hooked in closed season while fishing for coho. However, that is not what the proposal writers are wanting. They do not want the Department to go to catch and release when the targeted fishery is nearly closed because of conservation reasons. I think the Department really did not want to get into this at the Board meeting so read these proposals very very narrowly.
Another thing I found interesting in the whole sport fish vs commercial fishery comments is that the sport fish comments talk about reducing sport fishing opportunity but the commercial comments never mention commercial fishing opportunity as a goal. I just find that interesting as both are social issues and we know from studies in UCI that the social aspects of commercial fishing play a significant role in people's lives. Just interesting to see how the two fisheries are treated by the Department.